Buying the data is not illegal in Germany — sending to it without consent generally is, and that distinction is what your legal team is reacting to. German courts have consistently read the UWG as requiring prior consent for commercial email, including business-to-business, which makes Germany the strictest of the major European markets. There is no broad B2B carve-out of the kind the UK gives corporate subscribers or the Netherlands allows under legitimate interest.
What this means practically for a DACH expansion:
Email-first outbound into Germany does not work the way it does in the US or UK. Teams that succeed there use the purchased data differently — as an account and contact map for LinkedIn outreach, telephone contact within the permitted rules, event invitations, and targeted advertising audiences. The data is the targeting layer, not the send list.
If email is essential, consent has to be collected first. That means a German-language landing page, a gated asset worth downloading, and an opt-in that meets UWG standards — with the purchased file used to drive traffic to it through paid channels rather than through the inbox.
This is why we ask which market you are targeting before we build a file. For Germany we will tell you plainly that a standard outbound list is the wrong instrument, and we will build the account-mapping file instead — firmographics, decision-maker names and titles, and company-level detail, without positioning it as something you can cold-email. Our German coverage sits in the manufacturing and industrial verticals where it is deepest, and we will show you the count for your exact segment before you commit to anything.
This is general guidance, not legal advice. Your obligations depend on your entity, your channel mix and your use of the data — confirm with German counsel before launch.